Justia Criminal Law Opinion Summaries

After a woman sold drugs to an undercover officer and left in a car driven by the defendant, police arrested the defendant and recovered nearly $700—including prerecorded bills from the drug purchase—and a bag containing thirty-three grams of a white, powder-like substance from his person. Police also found a firearm, a scale, and additional currency in the car. The defendant was indicted on multiple drug and gun charges, including possession with intent to distribute (PWID) cocaine while armed and unlawful possession of a firearm by a felon (FIP). Before trial, the government dismissed several charges, dropped the while armed enhancement, and elected to proceed on attempted PWID cocaine as a lesser included offense. The defense did not object to these changes.During trial in the Superior Court of the District of Columbia, two officers testified that the bag contained a substance consistent with cocaine, but the court sustained defense objections to testimony that the substance was definitively cocaine, as no testing evidence was presented. After the government stated it was resting its case, the defense moved for judgment of acquittal, arguing insufficient proof regarding both the controlled substance and the firearm charge. The trial court permitted the government to reopen its case to admit a stipulation—previously agreed to by the parties—that the defendant had a prior felony conviction and knew of it, curing a deficiency on the FIP charge. The court denied the acquittal motion, finding the evidence sufficient.On appeal, the District of Columbia Court of Appeals held that the trial court did not abuse its discretion in allowing the government to reopen its case to admit the stipulation. The appellate court affirmed the FIP conviction. Regarding the attempted PWID charge, the court concluded that, because the jury convicted the defendant of attempted PWID of an unspecified controlled substance (rather than cocaine specifically), the felony conviction and sentence for attempted PWID cocaine was improper. The appellate court vacated the felony conviction and remanded for entry of a misdemeanor conviction and resentencing. View "Pritchett v United States" on Justia Law

Benjamin Higgerson was originally sentenced to 78 months in prison and ten years of supervised release after pleading guilty to possession of child pornography. Following his release, he repeatedly violated the terms of his supervised release, including failing to seek approved employment, missing restitution payments, and skipping sex offender treatment sessions. The United States District Court for the Southern District of Iowa revoked his supervised release twice, each time imposing nine months of imprisonment and a new nine-year term of supervised release. Upon beginning his third term, Higgerson failed to report to a designated homeless shelter and did not check in with his probation officer, resulting in further Grade C violations.After these violations, the district court conducted a third revocation hearing. The government requested a sentence above the guideline range due to Higgerson’s repeated noncompliance. Higgerson’s counsel argued for a lower sentence, citing his lack of housing. The district court imposed an 18-month sentence of imprisonment and a subsequent nine-year term of supervised release, with conditions including a residential reentry center placement. Higgerson did not object to the factors considered at sentencing.On appeal to the United States Court of Appeals for the Eighth Circuit, Higgerson argued that the district court improperly considered “promoting respect for the law,” a factor excluded from revocation sentencing under 18 U.S.C. § 3583(e). The Eighth Circuit applied plain error review, in light of the Supreme Court’s decision in Esteras v. United States, which prohibits consideration of “respect for the law” in revocation sentences. The Eighth Circuit found no clear or obvious reliance on the excluded factor and concluded that the district court’s reasoning focused on deterrence, incapacitation, and rehabilitation. The appellate court affirmed the district court’s judgment, holding that the sentence was not substantively unreasonable. View "United States v. Higgerson" on Justia Law

In January 2023, Jones J. Woods was charged with depredation against federal property after throwing rocks at windows of the United States Attorney’s Office in Buffalo, New York. Woods exhibited erratic behavior during court appearances in the United States District Court for the Western District of New York, prompting a psychiatric evaluation. In June 2023, the court found him incompetent to stand trial and ordered hospitalization for up to four months to determine if competency could be restored. After delays, Woods was hospitalized in January 2024, but after four months, he remained in custody at FMC Devens. In August 2024, following an evaluation, a Magistrate Judge found no substantial probability Woods would be restored to competency and ordered an additional 45 days of hospitalization, also directing an evaluation of dangerousness.Woods appealed the Magistrate Judge’s order to the United States District Court for the Western District of New York, which affirmed the order in September 2024. Meanwhile, the government filed a certificate of dangerousness, staying Woods’s release and initiating civil commitment proceedings in the District of Massachusetts. Woods challenged the validity of the extension of his hospitalization, arguing the district court lacked authority under the relevant statutes once the initial four-month period had expired and no restoration of competency was likely.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that Woods’s appeal was moot as to the dangerousness evaluation, since it had been completed and relief was not available. However, the appeal was not moot regarding the 45-day extension of hospitalization, as vacatur could affect ongoing civil commitment proceedings. On the merits, the Second Circuit affirmed the district court’s authority under 18 U.S.C. § 4241(d)(2)(B) to order continued custodial hospitalization for a reasonable period after the initial four months if charges were not yet disposed of, even when restoration of competency was deemed unlikely. The remainder of Woods’s appeal was dismissed as moot. View "United States v. Woods" on Justia Law

Over a five-year period, the defendant participated in a conspiracy to manufacture and distribute 16.1 million counterfeit alprazolam pills, which were sold via the dark web and other channels. The pills imitated the appearance and markings of legitimate FDA-approved alprazolam, but often contained benzodiazepine-class substances that were not scheduled as controlled substances at the time. The defendant marketed these pills as indistinguishable from legitimate products, and received payment in cryptocurrencies.The United States District Court for the Eastern District of Kentucky accepted the defendant’s guilty plea to conspiracy and counterfeiting charges. During sentencing, the court adopted the government’s proposed method for calculating loss under § 2B1.1 of the Sentencing Guidelines, using the estimated street price of $2 per pill to determine a total loss amount of approximately $32 million. The court also applied enhancements for victim numerosity or mass-marketing and for conscious or reckless risk of death or serious bodily injury, resulting in a total offense level of 35. The defendant was sentenced to 90 months’ imprisonment. Both parties objected to the loss calculation and enhancements, but the court overruled the objections after a joint evidentiary hearing.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s sentence. The appellate court held that the district court properly interpreted and applied Application Note 3(E)(v) of the Sentencing Guidelines, which requires loss to include the amount paid by end-users for misrepresented goods. It found no clear error in using the street price to calculate loss, nor in applying the enhancements for ten or more victims and for conscious or reckless risk of death or serious bodily injury. The sentence was affirmed in full. View "United States v. Wala" on Justia Law

Lawrence Levon Jones was investigated by Raleigh police as a suspected drug supplier during a larger drug-trafficking operation in 2020. Officers monitored a suspected stash house and wiretapped Jones’s phone, observing frequent visits by Jones and connections with other individuals involved in drug distribution. Jones financed marijuana purchases via Wesley Kelly, who transported drugs between California and North Carolina. Coordinated arrests and searches in July 2020 resulted in the seizure of large quantities of drugs, cash, and firearms from the stash house and related locations. Jones was arrested at the stash house and later made jail calls directing associates to move large sums of money.The United States District Court for the Eastern District of North Carolina charged Jones and others with several drug and firearms offenses. Jones was specifically indicted on four counts, including drug conspiracy and firearms possession. At trial, the government presented testimony from investigators and Kelly, a cooperating witness. The district court excluded evidence of Kelly’s decades-old federal drug convictions under Federal Rule of Evidence 609(b). After the government’s case, Jones moved for acquittal on the firearms charges, arguing lack of evidence of possession; the court denied the motion. The jury found Jones guilty on all counts. During sentencing, Jones objected to enhancements for obstruction and leadership, but the district court overruled these objections and imposed a sentence of 480 months.On appeal to the United States Court of Appeals for the Fourth Circuit, Jones challenged the exclusion of Kelly’s convictions, the denial of his motion for acquittal, and the sentencing enhancements. The Fourth Circuit held that the district court did not abuse its discretion in excluding impeachment evidence, that sufficient evidence supported the firearms convictions under constructive possession principles, and that the sentencing enhancements were not clearly erroneous. The Court also found that any error would have been harmless given Jones’s guidelines range. The judgment of the district court was affirmed. View "United States v. Jones" on Justia Law

A jury found the defendant guilty of unlawfully taking or driving a vehicle, conspiracy to commit vehicle theft, and receiving stolen property after he was observed towing a motorhome from an unoccupied property using makeshift equipment taken from the premises. He did not have permission to move either the motorhome or the equipment. The charges included allegations of prior convictions relating to vehicle theft and strike priors. The defendant waived his right to a jury trial on the priors and stipulated to one prior strike in exchange for dismissal of the other two.The Superior Court of San Diego County sentenced the defendant to six years on count one (three years, doubled for the strike), four years on count two (stayed under Penal Code section 654), and one year on count four (to run concurrently). The defendant appealed, alleging a violation of the Racial Justice Act (RJA) due to the use of a dog analogy during voir dire and closing arguments, and asserting several sentencing errors, including the procedure for priors and the application of sentences.The California Court of Appeal, Fourth Appellate District, Division One, held that the defendant forfeited the RJA claim by failing to object at trial and that, even if considered on the merits, the dog analogy did not constitute racially discriminatory language under section 745. The court also found sentencing errors: there were no findings on the prior convictions supporting the enhanced sentence under Penal Code section 666.5, and the defendant did not personally admit the strike prior. The court remanded the matter for resentencing to include a court trial on the qualifying prior conviction and confirmation of the strike admission, but affirmed the judgment in all other respects. View "P. v. Gomez" on Justia Law

Anthony Carter was accused of killing his girlfriend, Ashley Neville, in Columbus, Indiana. After a late-night argument, Carter entered Neville’s bedroom and shot her in the head. When she survived the gunshot, Carter strangled her with his hands, then placed a plastic grocery bag over her head and secured it with duct tape, ultimately suffocating her. Carter later confessed to his daughter and law enforcement, giving varying accounts about whether the shooting was intentional or accidental. Neville’s autopsy revealed death from both the gunshot wound and asphyxiation, with physical evidence supporting both causes.The State charged Carter with murder and sought a life without parole sentence, alleging three statutory aggravators: Carter was on probation for two felonies at the time, and he tortured Neville. During the jury trial in Bartholomew Superior Court 1, Carter argued that the shooting was accidental and requested a lesser-included instruction for reckless homicide, which the trial court declined, reasoning there was no serious dispute about Carter’s intent in the subsequent asphyxiation. The jury found Carter guilty of murder and all three aggravators, recommending life without parole, which the trial court imposed.Reviewing the direct appeal, the Indiana Supreme Court addressed whether the trial court erred in declining the reckless homicide instruction and whether sufficient evidence supported the torture aggravator. The Supreme Court held that the trial court did not abuse its discretion, as Carter’s intentional acts following the gunshot established murder rather than reckless homicide, regardless of the gunshot’s primary role. The Court also found sufficient evidence for the torture aggravator, citing Carter’s prolonged and gratuitous infliction of pain. Accordingly, the Indiana Supreme Court affirmed Carter’s conviction and sentence of life imprisonment without parole. View "Carter v. State of Indiana" on Justia Law

Late at night, a police officer in Jefferson City observed a vehicle behaving suspiciously in a closed business area known for crime. The officer stopped the vehicle, which was driven by James Eggleston with a female passenger. The passenger appeared to be under the influence of narcotics, and Eggleston volunteered that he had an outstanding warrant and did not consent to a search of the vehicle. After arresting Eggleston, the officer contacted a canine unit. The canine alerted to the driver's side, leading officers to search the vehicle and find a bottle containing four baggies of methamphetamine within easy reach of the driver's seat. Additional drug paraphernalia and the passenger’s identification were found on the passenger side.The State charged Eggleston with possession of a controlled substance in violation of Missouri law. Following a bench trial in the Circuit Court of Cole County, the judge found Eggleston guilty and sentenced him to three years in prison. Eggleston appealed, arguing that the evidence was insufficient to prove he knowingly possessed the methamphetamine, particularly since it was in a shared compartment and could have belonged to the passenger.The Supreme Court of Missouri reviewed the case, applying the statutory definitions of “knowingly” and “possessed” and clarifying that joint possession does not require “additional incriminating evidence” beyond proximity and control. The court held that circumstantial evidence, including the methamphetamine’s location within Eggleston’s reach, his conduct, and other contextual facts, was sufficient for a rational factfinder to conclude he knowingly possessed the controlled substance. The Supreme Court of Missouri affirmed the circuit court’s judgment, holding that the conviction was supported by sufficient evidence and rejecting prior case law that imposed heightened burdens in joint possession cases. View "State of Missouri vs. Eggleston" on Justia Law

Amanda Rogers was convicted of unlawful possession of a firearm by a felon after an incident in which she drove a vehicle with a passenger, Seller, who attempted to sell a gun to Informant. Informant notified law enforcement after Seller, a known felon, tried to sell him a firearm and could not provide proof of ownership. Rogers drove Seller to meet Informant; after the attempted sale, Informant described the vehicle, its occupants, and its direction to law enforcement. Trooper Enderle located the vehicle, initiated a stop after backup arrived, and found Rogers acting suspiciously. A subsequent search revealed compatible ammunition on the driver’s side and a firearm within easy reach of both front seats. Rogers denied knowledge of a firearm and refused consent to search. After a canine unit arrived, law enforcement found the firearm in a bucket between the seats.The Circuit Court of Polk County, following a jury verdict of guilty, sentenced Rogers to seven years’ imprisonment and placed her in a long-term treatment program. Rogers moved to suppress the firearm and ammunition, arguing lack of probable cause for the stop and insufficient evidence of knowing possession. The circuit court denied both motions. She appealed, raising the same issues, and the Missouri Court of Appeals reviewed the case before the Supreme Court of Missouri granted transfer.The Supreme Court of Missouri held that the state presented sufficient evidence for a reasonable factfinder to conclude Rogers knowingly possessed the firearm, applying statutory definitions of possession and knowledge, and rejected the requirement for “additional incriminating evidence” in joint possession cases. The Court also found that Trooper Enderle had probable cause to search the vehicle, based on Informant’s tip, corroborating circumstances, and Rogers’ conduct. The judgment of the circuit court was affirmed. View "State of Missouri vs. Rogers" on Justia Law

Two individuals were found sleeping in a parked car outside a casino in Kalispell, Montana, prompting an employee to request law enforcement both conduct a welfare check and ask the occupants to leave the premises. Flathead County Sheriff’s Deputies approached the vehicle, spoke with the occupants—Christina Torres and Randy Joe Fish—and requested Fish’s identification. After Fish provided his name and date of birth, a warrant check revealed Fish had an outstanding arrest warrant. Fish was arrested, and a subsequent search uncovered less than 0.1 gram of methamphetamine in his pocket.Fish was charged with Felony Criminal Possession of Dangerous Drugs in the Eleventh Judicial District Court, Flathead County. He moved to suppress the methamphetamine evidence, arguing the officers conducted a Terry stop without sufficient justification since they requested his name absent reasonable suspicion of illegal activity, thus violating his constitutional rights. The State responded that the interaction did not amount to a seizure, or alternatively, that the officers had particularized suspicion to investigate a possible trespass. After an evidentiary hearing, the District Court denied Fish’s suppression motion, concluding there was no Terry violation because the deputies acted appropriately given the circumstances and the property owner’s request.The Supreme Court of the State of Montana reviewed the District Court’s denial of the suppression motion. It presumed Fish was seized for constitutional analysis but found the initial police contact was justified under the community caretaker doctrine. When the welfare check was complete, the deputies had particularized suspicion to investigate trespass due to the request to remove Fish from the property. The Court held the officers’ actions did not violate the Fourth Amendment or Article II, Section 11 of the Montana Constitution and affirmed the District Court’s denial of Fish’s motion to suppress. View "State v. Fish" on Justia Law